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Official guidance
Partnership Manual

PM280000 · Overseas partnerships & treatment for UK tax purposes

  • PM281100 · UK resident members
  • PM281200 · Non-resident members: individuals
  • PM281300 · Non-resident members: companies
  • PM281400 · Non-resident company members trading in the UK
  • PM281500 · Non-resident company members not trading in the UK
  • PM282000 · Certificates of residence
  • PM283000 · Management and control
  • PM284000 · Where are the profits earned?
  • PM285000 · Composite SA returns for non-resident individual members
  • PM286000 · Investment partnerships
  • PM287000 · UK registered partnership with no UK source income or gain
  • PM288000 · Tax status of overseas partnerships
  • PM289000 · UK branches of overseas partnerships
  • PM290000 · Summary of filing requirements for partnerships with foreign aspects
  • PM291000 · Double taxation
  • PM292000 · Hybrid entities and tax arbitrage
  • PM293000 · Overseas partners in investment partnerships
  1. Overseas partnerships & treatment for UK tax purposes: contents
  2. Certificates of residence

PM282000 | Certificates of residence

From HM Revenue & Customs · Partnership Manual

As partnerships are not liable to tax in the UK, they cannot be ‘resident in the UK’ for the purposes of any of the UK’s Double Tax Conventions (DTCs). As such a formal ‘certificate of residence’ cannot be provided. However, HMRC will assist UK resident partners to claim the benefits of any DTC to which they are entitled by providing a letter of confirmation.

The instructions at INTM162110 set out what information is required from the partnership before confirmation can be issued. A form of wording is also provided for the letter and should be strictly adhered to.

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